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Regulation (EU) 2088/2019 (“SFDR Regulation”) provides that financial market participants and financial advisors are required to integrate the sustainability risk assessment.

Sibilla Capital Management LLC is obliged to follow the above regulation on the Ucits-compliant funds it manages.

The sustainability risks are defined in art. 2, no. 22) of the SFDR Regulation, as events or conditions environmental, social or governance type which, if they occur, could result in a significant actual or potential negative impact on the value of the investment.

In particular:

  • the risks of environmental sustainability are attributable to climate change, emissions of carbon dioxide, air pollution, water pollution, damage to biodiversity, deforestation, energy inefficiency, bad waste management practices, increased water scarcity, sea level rise / coastal flooding and fires;
  • the risks of social sustainability refer to violations of human rights, human trafficking, modern slavery / forced labor, labor rights violations, child labor, discrimination, restrictions or abuses of consumer rights, limited access to clean water, to a reliable food supply and / or a sanitary living environment and violations of rights of local communities / indigenous people
  • governance sustainability risks are associated with a lack of diversity at the level of board of directors, inadequate internal or external audit, violation or limitation of rights of (minority) shareholders, corruption, lack of control over the remuneration of executives, poor guarantees on personal data / IT security (of employees and / or customers), discriminatory work practices, health and safety issues for the workforce, bad sustainability practices in the supply chain, harassment in the workplace, discrimination and bullying, restrictions on collective bargaining or trade union rights, inadequate protection for whistleblowers and failure to meet minimum wage requirements or (if case) of living wages.

The sustainability risks are integrated into the processes management decisions and are identified, managed and monitored by the investment team, under the supervision of the Risk Management Function.

The Ucits -compliant fund managed by Sibilla Capital Management LLC fall within the definition of Art. 6 of the SFDR.